Privacy Notice

Culture

Privacy Notice

Privacy Notice

We recognise that protecting personal information is very important to you
and that you have an interest in how we collect, use, store and share such
information. We always respect our customers’ privacy and personal
information and we take this matter very seriously. We have worked very
hard to earn our customers’ trust and keeping it is our top priority.
That’s why we comply with the obligations that are laid out under data
protection laws.

This privacy notice sets out how we, as a data controller, will use and
protect your information. We will use your personal information only for
the purposes and in the manner set out in this privacy notice. We recommend
that you read this privacy notice carefully.

Please note: you have the right to object to the processing of your
personal data where that processing is carried out for our legitimate
interests or for direct marketing purposes.

1. About us

dingconnect.com
and dingconnect.com/portal
(the “Website”) is operated by, and the top-up services (“ Services”) are provided by, Ezetop Unlimited Company t/a
Ding (“Ding”, “we” or “ us”).
We are registered in Ireland with registered number 422514 and we have
our registered office at 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, Ireland.
Our VAT number is 9576713i. Ding is a registered business name of Ezetop Unlimited Company.

All correspondence in relation to any Ding company should be sent to
3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, Ireland.

2. How can you get in contact with Ding?

If you have any questions about this privacy notice or any other queries or
complaints, our Partner Support team is here to help – please contact us at partnersupport@ding.com
.

3. Scope of Ding’s privacy notice?

Personal data is information that identifies a person or can be used to
identify a person. For us to provide our Services to you, we need to
collect and process personal data about you. Without this information, we
may not be able to provide our Services to you.

This privacy notice will apply to personal data about you collected by us
through the Website or otherwise. It also applies to any third parties
whose personal data you provide to us in respect of which we are a data
controller. You acknowledge that you have informed any such third party
that their personal data may be collected and processed by Ding and made
them aware of this privacy notice.

Any changes to Ding’s privacy notice will be posted clearly on our Website.

Correspondence and complaints:
any correspondence that you choose to send to Ding (including
complaints); any information you provide to our partner support team;
any information you publish about Ding (including on the app stores).

Transaction History
: details of the top-up transactions you carry out on, and your visits
to, the Website.

For more information on the cookies we use, please see our cookies
statement here.

5. How does Ding collect your personal data?

You provide us with your personal data when you register for, or use our
Services. We may also collect personal data about you from third parties
(e.g. in the event of chargebacks or through third party direct marketing
services). We also collect information about you through your use of our
Website, your visits to our Website and details of the transactions you
carry out on our Website. When you visit our Website, your device and/or
browser may automatically disclose certain information (such as device
type, operating system, browser type, browser settings, IP address,
language settings, dates and times of connection to the Website or other
technical communications information), some of which may constitute
personal data.

6.
Why do we process your personal data and what is our legal basis for
doing so?

Reason for processing personal data

Legal Basis for processing your personal data

To help you purchase the Services that you have requested
and to process any payment connected with that Services
request

The use is necessary for the performance of a contract to
which you are a party or in order to take steps at your
request prior to entering a contract

To deliver the Services that you have requested to the
recipient of the Services

The use is necessary for the performance of a contract to
which you are a party or in order to take steps at your
request prior to entering a contract

To contact you if it's required in relation to the Services
that you have sent or to reply to any communications that
you might have sent us

The use is necessary for the performance of a contract to
which you are a party or in order to take steps at your
request prior to entering a contract

To provide you with information on products or services
that might interest you

The use is necessary for the purpose of our legitimate
interests

To notify you about any changes to the Website or Services

The use is necessary for the purpose of our legitimate
interests

To ensure that content on the Website is presented in the
most effective manner for you and your device

The use is necessary for the purpose of our legitimate
interests

To provide you with partner support

The use is necessary for the purpose of our legitimate
interests

For marketing analysis

The use is necessary for the purpose of our legitimate
interests

For security and fraud prevention purposes

The use is necessary for compliance with our legal
obligations

To help improve our Website and our Services

The use is necessary for the purpose of our legitimate
interests

We will also process personal data as is necessary to comply with any of
our legal obligations. We will inform you in advance if we intend to
further process your personal data for a purpose other than as set out
above. We will also seek your specific consent to the processing of
personal data for other specific purposes. You will have the right to
withdraw such consent at any time.

7.
Do we carry out any automated processing of your personal data?

No, we do not currently carry out any automated processing of your personal
data. If, at any point in the future, we make solely automated decisions
that affect you in a legal or a significant way, we will inform you of this
processing. you will have the right to provide your point of view and have
those decisions reviewed by a member of our staff.

8.
What happens if you do not provide us with your personal data?

If you do not provide us with your personal data or object to the use of
certain personal data, we may not be able to provide the Services to you.
We will tell you when we ask for information which is a contractual
requirement or needed to comply with our legal obligations.

9. Who do we disclose your personal data to?

We currently share your personal data, where necessary, with the following
recipients:

you and, where you request, any third party you ask us to share it
with;

anti-fraud service providers;

governmental, legal, regulatory, or similar authorities, on request or
where required, including for the purposes of reporting any actual or
suspected breach of applicable law or regulation;

third party payment processors;

direct marketing service providers;

data analytics service providers (e.g. Google Analytics);

third party service providers used for the delivery of some aspects of
the Services (e.g. SMS delivery, email delivery, web notifications and
phone number lookup);

hosting infrastructure companies based in the EEA;

potential purchasers or bidders.

10. Does Ding transfer your personal data outside the EEA?

Ding may be required to transfer your personal data outside the EEA for the
purposes of providing the Services. To ensure that your personal data
receives an adequate level of protection and is treated securely, we have
put the appropriate safeguards in place to protect the privacy and
integrity of such personal data when being transferred outside the EEA
(e.g. EU-approved standard contractual clauses / U.S. Privacy Shield /
binding corporate rules).

11. What if Ding is bought by another company?

We reserve the right to transfer information (including your personal data)
to a third party in the event of a sale, merger, liquidation, receivership
or transfer of all or substantially all of the assets of our company. The
third party must only use your personal data for the purposes that you
provided it to us in the first place and as set out in this privacy notice.
You will be notified in the event of any such transfer.

12. Data Security

We have implemented appropriate technical and organisational security
measures designed to protect your personal data against accidental or
unlawful destruction, loss, alteration, unauthorised disclosure,
unauthorised access, and other unlawful or unauthorised forms of
Processing, in accordance with data protection laws.

You are responsible for ensuring that any personal data that is sent to us
is sent securely.

13. How long do we keep your personal data?

We will keep your personal data only for so long as is necessary to carry
out the purposes set out above and to comply with any legal obligations.
The criteria for determining the duration for which we retain your personal
data are whether it is necessary:

to maintain an ongoing relationship with you (e.g. to provide our
Services to you or where you are lawfully included in our direct marketing
lists and have not unsubscribed);

in connection with the lawful purposes set out in this policy, or where
we have a valid legal basis; or

to comply with any applicable limitation period under applicable law, and
a reasonable amount thereafter.

Once the periods above have concluded, we will either:

permanently delete or destroy the relevant personal data;

archive your personal data so that it is beyond use; or

anonymise the relevant personal data.

14. Where does Ding hold your personal data?

Your personal data is held on secure servers which are hosted by Ding or by
a third party hosting infrastructure company located within the EEA.

15. Your Rights

You have a right to obtain a copy of, and the right to rectify any
inaccuracies in, the personal data we hold about you by making a request to
us in writing. You also have the right to request erasure, restriction,
portability or object to the processing of your personal data or not to be
subject to a decision based on automated processing, including profiling.
You should inform us of any changes to your personal data. Any requests
made under this section can be made using the contact details set out
below. We will respond to your request in writing, or orally if requested,
as soon as practicable and in any event not more than one month after
receipt of your request. You have the right to lodge a complaint with the
Office of the Data Protection Commission if unhappy with how your personal
data is being handled. Their contact details are as follows:

If we are relying on your consent to allow us to process your information,
you can withdraw your consent at any time. From that point on we would no
longer be able to carry out the processing we were carrying out with your
consent. Any processing we carried out before you withdrew your consent
would remain valid. We do not generally rely on consent for processing
personal data.

Please contact us at partnersupport@ding.com
or at Ding, 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, Ireland,
Ireland to exercise any of your rights under this section.

16. Will Ding use your personal data for direct marketing purposes?

Where we have your consent to do so, we will use your personal data to send
you information by SMS or email relating to our products and services which
may be of interest to you or similar products and services to those you
have previously purchased from Ding.

17. Can you opt-out/unsubscribe from direct marketing?

You will be provided with an opportunity to opt-out opt-out at any time,
free of charge, by: (i) for SMS and email, by using the unsubscribe
facility in the SMS or email that Ding sends to you; or (ii) by sending an
email to partnersupport@ding.com.

Ding does not sell or share your personal data with subsidiary companies or
third parties for marketing or profit purposes.